State v. Hairston, 97 N.E.3d 784

Officers responded to a 9:00 p.m. domestic dispute call and, upon exiting their patrol car, heard four or five gunshots coming from the west toward a nearby elementary school.
Officers drove about four-tenths of a mile and within 30–60 seconds arrived near the school, where they observed Jaonte Hairston walking east across a crosswalk, talking on a cell phone; it was dark and no one else was present.
Officers exited with guns drawn, ordered Hairston to stop, asked if he heard shots, and asked about weapons; Hairston acknowledged hearing shots and indicated a gun in his left jacket pocket.
Officers recovered a semiautomatic pistol from Hairston after a pat-down; Hairston was charged with carrying a concealed weapon and moved to suppress the firearm as the product of an unlawful seizure.
The trial court denied the motion to suppress, finding officers had reasonable suspicion for a Terry stop; Hairston pled no contest, was sentenced, and appealed the suppression ruling.
The appellate court reviewed de novo whether the facts supported reasonable suspicion and reversed, concluding the stop lacked the particularized suspicion required by Terry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, particularized suspicion to make an investigatory stop after hearing nearby gunshots	Contextual factors (proximity/timing of shots, high-crime area, absence of others, Hairston’s nervousness) gave reasonable suspicion to stop Hairston	Hearing gunshots alone, then stopping the first person seen without a particularized link, is merely a hunch and insufficient under Terry	No — the court held the totality of circumstances did not produce an objective, particularized basis to suspect Hairston; the stop lacked reasonable suspicion
Whether stopping Hairston at gunpoint was justified by elevated safety concerns	Officers’ display of force was reasonable given they had just heard gunshots and needed to ensure safety	Elevated show of force requires a stronger, particularized basis than existed here	Not justified — point-of-gun seizure without particularized suspicion rendered the stop unconstitutional

Terry v. Ohio, 392 U.S. 1 (establishes investigatory stop / reasonable suspicion standard)
United States v. Cortez, 449 U.S. 411 (totality-of-the-circumstances and particularized suspicion requirement)
Ornelas v. United States, 517 U.S. 690 (de novo appellate review of reasonable suspicion/probable cause)
Katz v. United States, 389 U.S. 347 (warrant requirement and Fourth Amendment protection)
Brown v. Texas, 443 U.S. 47 (presence in a high-crime area alone cannot justify a stop)
Illinois v. Wardlow, 528 U.S. 119 (flight and evasive behavior can support reasonable suspicion when present)
Carroll v. United States, 267 U.S. 132 (reasonableness judged by what facts were available to the officer)